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RIGGER

RSL REMOVED FROM JAVELIN H/C BY RIGGERS

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Good luck arguing "well I didn't think that employee of the manufacturer knew what they were on about, so I ignored them".

For the record, I didn't read any implications about other containers on the market - the thread title contains "Javelin", doesn't it? wsinsel called Sunpath and they told him that removing the factory-installed RSL was an alteration. Ergo, it's an alteration. Where's the grey area? Is there something I'm completely missing?

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WHAT?????????????????????????? By YOUR logic anyone can just willy-nilly cut stuff off a rig and hand them out as if nobody cared. I guess you follow YOUR little rules when and if you want and I'll just call the manufacturer.




He wasn't talking about cutting anything off of a rig.

He was talking about removing a part of a container, that by design, can be removed, and in most cases is optional.

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I just now called Sunpath and asked Dave.....He says it is an alteration to remove the RSL from any rig that was manufactured with it. As a rigger that is all I ever need to know. End of story.



Proper phrasing would say "any Javelin"
----------------------------------------------
You're not as good as you think you are. Seriously.

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Mike,
Why would it not be true?
The definition of an alteration is a change from the original configuration from which it was manufactured.

Also:

B. Any change to the configuration, method of
operation, or method of packing the main parachute, up to
and including the main canopy attachment links or the male
end of the quick release fittings, is a main pack alteration.
Any main parachute alteration that affects the strength or
operation of the auxiliary parachute
, including the harness,
must be regarded as an alteration of the auxiliary parachute
and handled accordingly.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Mike,
Why would it not be true?
The definition of an alteration is a change from the original configuration from which it was manufactured.

Also:

B. Any change to the configuration, method of
operation, or method of packing the main parachute, up to
and including the main canopy attachment links or the male
end of the quick release fittings, is a main pack alteration.
Any main parachute alteration that affects the strength or
operation of the auxiliary parachute
, including the harness,
must be regarded as an alteration of the auxiliary parachute
and handled accordingly.


MEL



When the harness/container and the reseve canopy for that matter are tested and manufactured how in the hell do they know what kind of main canopy will be used much less how it will be packed.

Can you explain how the method of packing a main "that affects the strength or operation of the auxiliary parachute,"?
My idea of a fair fight is clubbing baby seals

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that affects the strength or
operation of the auxiliary parachute
, including the harness,
must be regarded as an alteration of the auxiliary parachute
and handled accordingly.


MEL


So, by removing the RSL LANYARD you're affecting the operation of the auxialiary parachute? If you think so, then releasing the snap shackle has the same effect, so that would be an alteration also.

Again, removing RSL LANYARD = OK, removing provisions for mounting RSL LANYARD (velcro, rings, etc.) = BAD

Where did Shlomo go anyway? Starts up a shitstorm and then goes quiet when it starts getting good:D I'll bet he's brewing up something else:D

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Picture this if you can. A H/C is shipped unassembled. By your logic the person who assembles it must be a master rigger to INSTALL the RSL in the first place.

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as well as installing connector links and AAD. I'm going to make a statement here that is in no FAR's or manuals that makes since on assembly/repairs/alterations. To all who post here feel free to criticize. ' Any rigging that can or may cause a catastrophy should be done by a Master Rigger and/or the manufacturer of the equipment'.' Such as the assembly of parachute components, replacing lines, installing AAD, retrofit AAD pocket, removing/adding RSL, sewing on H/C and canopies'. I learned this from an old rigger, it just made since. When i worked for him, he assembled gear i inpected and packed, as a senior rigger. Good ethics I thought.

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What is your interpretation of the rules when the manufacture designs the systems to be altered as part of the normal function by the users?

Some manufactures build into the design the ability for the end user or rigger to remove items such as the RSL. Containers are becoming more modular in design and allow for variations in form, fit and function by the end users themselves.

I think that you are misinterpreting the intent of the rules.

And yes, there are manufactures that have already stated that they do not consider it an alteration.
Time and pressure will always show you who a person really is!

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What is your interpretation of the rules when the manufacture designs the systems to be altered as part of the normal function by the users?



Multi-functional

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Some manufactures build into the design the ability for the end user or rigger to remove items such as the RSL. Containers are becoming more modular in design and allow for variations in form, fit and function by the end users themselves.



I never said that disabling the RSL was an alteration.

I was referring to physically removing it.

If you remove it physically, like with the velcro or mounting appliances,I believe it would fall under the definition of alteration as the FAA sees it.

It would be interesting to know if the last two fatalities that occurred without RSLs attached at the WFFC, were removed from the rig physically, were ever installed at the factory, or just disabled.


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I think that you are misinterpreting the intent of the rules.



Could be, but I do not think so in this case.


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And yes, there are manufacturers that have already stated that they do not consider it an alteration.



First , the manufacturers conform to the rules set forth by the FAA. Not the other way around.

Once a rig leaves the domain of the manufacturer; i.e., in the field, the local FSDO takes over with who does what-where as far as modifications,alterations, and major repairs.

To show what I mean here, lets change the topic from an RSL to a BOC.

Lets say a rig left out of factory "A" with a ROL deployment pouch.

A end user now wants a BOC pouch installed.

Manufacturer "A" cannot issue a statement saying moving the location of the pouch is not an alteration, when the FAA says it is.

Also on that same note, Manufacturer "A" cannot issue a statement saying that a Senior rigger could move it. As you know only a master rigger can do it according to the FAA.

There are cases where this has happened.
It doesn't mean it it is legal.

You have to know your certificate privileges and limitations without relying on someone else or the manufacturer.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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You can attempt to make word changes but in the end that is all that it is. It does not matter if you undo the quick-relase or romve it because it still alters it's function.

Please provide written proof where a manufature authorized the removal of an RSL since it was an option as a non-alteration and the FAA vacated that decision, otherwise it is nothing more that speculation.
Time and pressure will always show you who a person really is!

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You can attempt to make word changes but in the end that is all that it is. It does not matter if you undo the quick-relase or romve it because it still alters it's function.


I do not know as to what word changes you are referring.
Agreed, Disabling the RSL alters it's function.

I am thinking alot like airplanes here since most of the FARs pertain to that.

Take an autopilot. you can enable it or disable it, whichever the case may be.

But if you remove it from the airplane, it would be a change from the manufacturers configuration if it came that way.


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Please provide written proof where a manufature authorized the removal of an RSL since it was an option as a non-alteration and the FAA vacated that decision, otherwise it is nothing more that speculation.



No one ever said there was written approval to remove an RSL.

That's the whole point of this thread.

What I am saying is that it is an alteration to physically remove one and if you were to remove one, you need the approval of the manufacturer and/or your local FSDO.
You also need to be a master rigger to do it.

Bill B.,care to comment here??

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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No one ever said there was written approval to remove an RSL.

Again, there has been other manufacturers that have and they do not consider it an alteration as it is an option.

And just because you remove something does not automatically make it an alteration and only a function that requires a master rigger. There are parts that can be removed by a senior rigger.
Time and pressure will always show you who a person really is!

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Again, there has been other manufacturers that have and they do not consider it an alteration as it is an option.



Mike,
Here again, the manufacturers do not have the authority to classify it as not an alteration.

Also, the option is (if installed) to enable it or disable it.

I guess the other option is to order it without the RSL installed if the manufacturer will send it out without one.

But once installed; we are back to the original point!

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Here again, the manufacturers do not have the authority to classify it as not an alteration.

Well until you can provide a letter ruling from the FAA, what you are saying is nothing more than an opinion, as the fact is that there is no standing ruling from the FAA vacating manufactures that have taken this position that I am aware of. Do you have any?

So in the end what we have is a long standing determination from some manufactures with no conflict ruling from the FAA and on the other side we have your opinion. That is all the information that I need.
Time and pressure will always show you who a person really is!

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Well until you can provide a letter ruling from the FAA, what you are saying is nothing more than an opinion, as the fact is that there is no standing ruling from the FAA vacating manufacture that have taken this position that I am aware of. Do you have any?



Do not need one!

The FAA definition of an alteration is all that I need.

Also the rules and guidelines for doing alterations, as I previously posted, should be followed.
If you do tht's one thing and if not that's another.

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So in the end what we have is a long standing determination from some manufactures with no conflict ruling from the FAA and on the other side we have your opinion. That is all the information that I need.



Granted, you have the right to your own opinion!



MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Granted, you have the right to your own opinion!

Thank you for letting me know that we have not given up the flag yet. But in this case I don't need it because I have the facts. We will just have to agree that your interpretation of the regulations are different than mine.
Time and pressure will always show you who a person really is!

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Thank you for letting me know that we have not given up the flag yet. But in this case I don't need it because I have the facts.



In your opinion, and yes, we can say mine is different.

MEL

PS- I only found Pilot Chutes in AC-105-2C that were applicable to Senior Riggers removing stuff.
there may be more, I did not spend alot of time on it.
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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:)
I'm here reading my fellows riggers posts & I do not understand why it is so hard for the riggers to except
that rmoving the RSL lanyard from the Javelin is an alteration NOT approved by the mfg. Sun Path.

Same with major repairs & reline of the main canopy which must be done by a Master Rigger only, it's by logic & by law & please do not start the issue again.

Would you like that a skydiver or a 24 hours Senior Rigger will do a major repair or will
reline a "Velocity" or any other Super H/P main canopy ??? or even the most simple student main. There is NO difference between a main & a reserve. They BOTH must fly & perform in the best SAFE mode !!!

Senior Riggers, please take your time & listen to Master Riggers, do not let your ticket & pride to let you do rigging works that you should not do.

What some riggers are fighting for ? the "Freedom to Choose" ? showing that riggers can do all ? playing the 'extreme" rigger that can do all ? my advice to you be an "Aviation" rigger, know the limits of your ticket & move on step by step.

As a rigger you must give the rig back to the owner packed & set according to the mfg. manuals & or any Service Bulletin if it's mandatory.

Some riggers will say now: Mandatory SB by the mfg. it is not a must because it does not came from the FAA.

My fellow riggers some of you must take a deep thinking about the way you understand yours ticket.

Rigging is not a hobby, it's a profession!!!

Safe Rigging !!!

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